SecProbe.io

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 February 10, 2026

Jorge F. Scarinci
Chief Financial Officer
Macro Bank Inc.
Avenida Eduardo Madero 1172, 24th Floor
C1106ACY City of Buenos Aires
Argentina

 Re: Macro Bank Inc.
 Form 20-F for Fiscal Year Ended December 31, 2024
 File No. 001-32827
Dear Jorge F. Scarinci:

 We have completed our review of your filing. We remind you that the
company and its
management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding
any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Paola Gayoso
</TEXT>
</DOCUMENT>

CORRESP
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 filename1.htm

 January 30, 2026

 Via EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Finance

 Attn: Victor Cecco and Michael Volley

 Re: Macro Bank Inc.

 Form 20-F for Fiscal Year Ended December 31, 2024

 File No. 001-32827

 Dear Mr. Cecco and Mr. Volley:

 Banco Macro S.A. ( Macro Bank Inc. ) (the
 "Bank" or "we") hereby submits this letter in response to the comments of the staff (the "Staff")
of the U.S. Securities and Exchange Commission (the "Commission") set forth in the Staff's letter dated January 15,
2026, providing the Staff's comments with respect to the above-referenced Form 20-F for the fiscal year ended December 31, 2024
(the "2024 Form 20-F").

 Set forth below are the Bank's responses
to the Staff's comments. For convenience, the Staff's comments are repeated below in italics, followed by the Bank's
response to the comments. Capitalized terms used but not defined within this letter have the meanings ascribed to them in the 2024 Form
20-F.

 1. Analysis of the allowance for loan losses and other financing, page 134
We acknowledge your response to prior comment one. Please revise future filings to provide qualitative information, including a narrative
explanation, to explain the reasons for the changes in the expected credit loss ("ECL") allowance during each period presented.
Refer to IFRS 7.35H, .35I and .B8D for guidance.

 Response : We respectfully acknowledge the
Staff's comment and confirm that we will revise future filings to provide qualitative information, including a narrative explanation,
to explain the reasons for the changes in the expected credit loss ("ECL") allowance during each period presented, as requested.

 2. Credit loss expense on financial assets, page 162

 · Please tell us and revise future filings,
as needed, to define "Charged-off Loans" and "Amounts Written Off" clearly identifying the differences between each
term as used in your prior reconciliation.

 Response : We respectfully acknowledge the
Staff's comment and confirm that we will revise future filings to clearly identify the differences between the definitions of "Charged-off
Loans" and "Amounts Written Off", if applicable.

 Charged-off Loans : this term refers, in
the explanations sent in our previous letter, to the increase in the credit loss expense recognized in the income statement for the period
that does not impact the Expected Credit Loss (ECL) allowance, but instead directly reduces the loans and other financing balance. These
charges arise from specific customer circumstances.

 Amounts Written Off : this term refers to
the amounts of loans and other financing that are settled in part or in full against the ECL allowance. Write-offs occur after the first
month in which the Bank has no reasonable expectations of recovering the financial instrument or a portion thereof. The amounts written
off are managed by the Bank through off balance sheet accounts.

 · Please provide us a reconciliation showing
how the credit loss expense recognized for 2024 and 2023 is presented in the ECL rollforward line-items on page 134. Please separately
identify amounts related to each various cause (e.g., "Charged-off Loans" and IAS 29 restatement).

 Credit loss expense on financial assets for the year ended on December 31, 2024
 108,107,103

 Credit loss (gain) related to debt securities
 (1,286,461 )

 Credit loss expense related to loans and other financing
 109,393,564

 Response : We respectfully acknowledge the
Staff's comment and advise that the table below presents a reconciliation of the credit loss expense recognized for 2024 and 2023
to the line items in the ECL rollforward, with separate identification of amounts related to each cause (including the breakdown of "Charged-off
Loans" and the IAS 29 restatement figures). The figures are presented in thousands of Pesos, in constant currency as of December
31, 2024.

 ECL as of January 1, 2024
 116,827,575

 Movements of ECL that impact in credit loss expense

 Credit loss expense related to Assets originated or purchased (a)
 84,313,999

 Credit loss expense related to Assets derecognized or repaid (b)
 (23,551,869 )

 Credit loss expense related to Assets held during the fiscal year (c)
 24,144,373

 Subtotal I Credit loss expense
 84,906,503

 Other movements of ECL that do not impact in credit loss expense

 Other Movements
 (6,144,212 )

 Amounts Written Off
 (5,542,952 )

 Monetary Effects for balances
 (66,692,317 )

 ECL as of December 31, 2024
 123,354,597

 Other charges to Credit loss expense

 IAS 29 restatement for results
 24,007,683

 Charged off Loans
 479,378

 Subtotal II Credit loss expense
 24,487,061

 Total Credit loss expense (Subtotal I + Subtotal II)
 109,393,564

 Credit loss expense on financial assets for the year ended on December 31, 2023
 100,103,207

 Credit loss expense related to debt securities
 36,880

 Credit loss expense related to loans and other financing
 100,066,327

 ECL as of January 1, 2023
 74,611,567

 Movements of ECL that impact in credit loss expense

 Credit loss expense related to Assets originated or purchased (a)
 18,802,778

 Credit loss expense related to Assets derecognized or repaid (b)
 (14,150,939 )

 Credit loss expense related to Assets held during the fiscal year (c)
 68,683,521

 Subtotal I Credit loss expense
 73,335,360

 Other movements of ECL that do not impact in credit loss expense

 Other Movements
 7,426,571

 Amounts Written Off
 (8,385,815 )

 ECL derived from acquired subsidiaries during the year
 61,838,790

 Monetary Effects for balances
 (91,998,898 )

 ECL as of December 31, 2023
 116,827,575

 Other charges to Credit loss expense

 IAS 29 restatement for results
 26,429,553

 Charged off Loans
 301,414

 Subtotal II Credit loss expense
 26,730,967

 Total Credit loss expense (Subtotal I + Subtotal II)
 100,066,327

 (a) It includes the movements in the ECL allowance for assets purchased or originated during the period, which
are recognized within the credit loss expense. In 2023, in the ECL rollforward included on page 134, this line included 61,838,790 derived
from acquired subsidiaries.

 (b) It includes the movements in the ECL allowance for assets derecognized or repaid during the period.

 (c) It includes changes (increases and decreases) to the ECL allowance related to loans and other financing
transactions that remained outstanding from the opening of the fiscal period to the end of such period .

 As of December 31, 2024, the "Other movements",
which amounted to 6,144,212 corresponds to loan portfolio sales and foreign exchange effects. These items impact the ECL allowance balance
without affecting the credit loss expense.

 As of December 31, 2023, the "Other movements",
which amounted to (7,426,571) corresponds to balances derived from acquired subsidiaries during the year, loan portfolio sales and foreign
exchange effects. These items impact the ECL allowance balance without affecting the credit loss expense.

 The "Monetary Effects for balances"
line item in the ECL rollforward presented above includes the impact of changes in the general price level on the ECL allowance balance,
measured from the revaluation date to the closing date of each reporting period. This adjustment is calculated by applying a general price
index to ensure that the comparative financial statements are presented in terms of the measuring unit current at the end of each reporting
period, in accordance with IAS 29

 · Please consider revising your ECL rollfoward,
supporting disclosure or other disclosure in future filings to more clearly show the relationship between the credit loss recognized in
the income statement and the line-items included in the ECL rollforward.

 Response : We respectfully acknowledge the
Staff's comment and confirm that we will revise future filings to more clearly show the relationship between the credit loss expense
and the ECL rollforward line items, as requested.

 If you have any questions or require any additional
information with respect to the above, please do not hesitate to contact me at +54 11 5222 6730 or jorgescarinci@macro.com.ar, or Emilio
Minvielle at +1 212 903 9407 or emilio.minvielle@linklaters.com of Linklaters LLP.

 Sincerely,

 /s/ Jorge F. Scarinci
By: Jorge F. Scarinci

 Title: Chief Financial Officer
Banco Macro S.A.

 cc: Paola Gayoso

 	 Banco Macro S.A.

 Matthew Poulter, Esq.

 Linklaters LLP

 Emilio Minvielle, Esq.

 Linklaters LLP

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 January 15, 2026

Jorge F. Scarinci
Chief Financial Officer
Macro Bank Inc.
Avenida Eduardo Madero 1172, 24th Floor
C1106ACY City of Buenos Aires
Argentina

 Re: Macro Bank Inc.
 Form 20-F for Fiscal Year Ended December 31, 2024
 Response Dated September 30, 2025
 File No. 001-32827
Dear Jorge F. Scarinci:

 We have reviewed your September 30, 2025 response to our comment letter
and have
the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our
September 16, 2025 letter.

Form 20-F for Fiscal Year Ended December 31, 2024
Analysis of the allowance for loan losses and other financing, page 134

1. We acknowledge your response to prior comment one. Please revise future
filings to
 provide qualitative information, including a narrative explanation, to
explain the
 reasons for the changes in the expected credit loss ( ECL )
allowance during each
 period presented. Refer to IFRS 7.35H, .35I and .B8D for guidance.
Credit loss expense on financial assets, page 162

2. We acknowledge your response to prior comment two. Please address the
following:

 Please tell us and revise future filings, as needed, to define
"Charged-off Loans"
 and "Amounts Written Off" clearly identifying the differences
between each term
 January 15, 2026
Page 2

 as used in your prior reconciliation.
 Please provide us a reconciliation showing how the credit loss
expense recognized
 for 2024 and 2023 is presented in the ECL rollforward line-items on
page 134.
 Please separately identify amounts related to each various cause
(e.g., "Charged-
 off Loans" and IAS 29 restatement).
 Please consider revising your ECL rollfoward, supporting
disclosure or other
 disclosure in future filings to more clearly show the relationship
between the
 credit loss recognized in the income statement and the line-items
included in the
 ECL rollforward.

 Please contact Victor Cecco at 202-551-2064 or Michael Volley at
202-551-3437 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Paola Gayoso
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CORRESP
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filename1.htm

September 30, 2025

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

Attn: Victor Cecco and Michael Volley

Re: Macro Bank Inc.

Form 20-F for Fiscal Year Ended December 31, 2024

File No. 001-32827

Dear Mr. Cecco and Mr. Volley:

Banco Macro S.A. (Macro Bank Inc.) (the
 “Bank” or “we”) hereby submits this letter in response to the comments of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter dated September 16,
2025, providing the Staff’s comments with respect to the above-referenced Form 20-F for the fiscal year ended December 31, 2024
(the “2024 Form 20-F”).

Set forth below are the Bank’s responses
to the Staff’s comments. For convenience, the Staff’s comments are repeated below in italics, followed by the Bank’s
response to the comments. Capitalized terms used but not defined within this letter have the meanings ascribed to them in the 2024 Form
20-F.

 1. Analysis of the allowance for loan losses and other financing, page 134

Please tell us and revise future filings to clarify what “variations” represent in your ECL rollforwards.

Response: We respectfully acknowledge the
Staff’s comment and advise the Staff that we will revise future filings to clarify the nature of the “variations” line
item in our ECL rollforwards.

For the ECL rollforward tables presented in the
2024 Form 20-F, “variations” represent changes (increases and decreases) to the expected credit loss (ECL) allowance relating
to loans and other financing transactions that remained outstanding from the opening of the fiscal period to the end of such period.

 2. Credit loss expense on financial assets, page 162

Please provide us and revise future
filings to disclose a breakdown of the credit loss expense on financial assets recognized in each period presented in your filing by nature
of financial asset. Also, provide us a reconciliation of the credit loss expense recognized for loans and other financing to the ECL rollforward
disclosed on page 134 for 2024 and 2023 and revise future filings as necessary to ensure investors understand the relationship between
the credit loss recognized and the line-items included in the ECL rollforward.

Response: We respectfully acknowledge the
Staff’s comment and confirm that we will revise future filings to disclose the credit loss expense on financial assets disaggregated
by nature of financial assets, and aggregating immaterial items as appropriate. In addition, we will include disclosure as necessary to
ensure investors understand the relationship between the credit loss expense recognized and the line-items included in the ECL rollforward.

 a. Breakdown of the credit loss expense by nature of financial asset:

For the year ended December 31, 2024, we recognized
a credit loss expense on financial assets of Ps. 108,107,103 thousand. This amount comprised an expense of Ps. 109,393,564 thousand related
to loans and other financing and a gain of Ps. 1,286,461 thousand related to debt securities.

For the year ended December 31, 2023, we recognized
a credit loss expense on financial assets of Ps. 100,103,207 thousand. This amount comprised an expense of Ps. 100,066,327 thousand related
to loans and other financing and an expense of Ps. 36,880 thousand related to debt securities.

 b. Reconciliation of credit loss expense for loans and other financing to the ECL rollforward:

In order to reconcile the credit loss expense
on financial assets to the ECL rollforward disclosed on page 134 of the 2024 Form 20-F, it should be noted that:

·       Certain
movements impact the credit loss expense but do not impact the ECL balance, such as loans charged off (i.e. debit to credit loss expense;
credit to loan receivables) and the restatement as of year-end as required by IAS 29 of the movements of the credit loss expense occurred
during the year;

·       Certain
movements included in the line-items of the ECL rollforward named “Amounts Written off” (i.e. debit to ECL; credit to loan
receivables) and “Monetary effects” (restatement of the movements of the ECL balance during the year, as required by IAS 29,
in order to show such movements in constant currency) impact the ECL balance but do not impact the credit loss expense; and

·       Other
movements (such as loan portfolio sales and foreign exchange effects) impact the allowance balance without affecting the credit loss expense.

The quantitative reconciliations for 2024 and
2023 are presented below (figures in thousands of Pesos, in constant currency as of December 31, 2024):

2024

    ECL as of 01/01/2024
      116,827,575

    ECL as of 12/31/2024
      123,354,597

    Net change in ECL balance
      6,527,022

    Credit loss expense recognized for loans and other financing
      109,393,564

    Movements that impact the credit loss expense but do not impact the ECL balance:

    *Charged-off loans and IAS 29 restatement
      (24,487,061 )

    Movements that impact the ECL balance but do not impact the credit loss expense:

    *Amounts Written off and monetary effects
      (72,235,269 )

    *Other movements
      (6,144,212 )

    Net change in ECL balance
      6,527,022

2023

    ECL as of 01/01/2023
      74,611,567

    ECL as of 12/31/2023
      116,827,575

    Net change in ECL balance
      42,216,008

    Credit loss expense recognized for loans and other financing
      100,066,327

    Movements
that impact the credit loss expense but do not impact the ECL balance:

    *Charged-off loans and IAS 29 restatement
      (26,730,967 )

    Movements
that impact the ECL balance but do not impact the credit loss expense:

    *Amounts Written off and monetary effects
      (100,384,713 )

    * ECL derived from acquired subsidiaries during the year
      61,838,790

    * Other movements
      7,426,571

    Net change in ECL balance
      42,216,008

 3. Income Tax, page F-71

Please revise future filings to separately
quantify the impact of each material item resulting in a material difference between your effective tax rate and the amounts obtained
by applying the current tax rate in Argentina to the income carrying amount.

Response: We respectfully acknowledge
the Staff’s comment and confirm that we will revise future filings to separately quantify and disclose each material item that
results in a material difference between our effective tax rate and the current tax rate in Argentina.

If you have any questions or require any additional
information with respect to the above, please do not hesitate to contact me at +54 11 5222 6730 or jorgescarinci@macro.com.ar,
or Emilio Minvielle at +1 212 903 9407 or emilio.minvielle@linklaters.com of Linklaters LLP.

Sincerely,

    /s/
    Jorge F. Scarinci

    By: Jorge F. Scarinci

    Title: Chief Financial Officer

    Banco Macro S.A.

    cc:
    Paola Gayoso

    Banco Macro S.A.

    Matthew Poulter, Esq.

    Linklaters LLP

    Emilio Minvielle, Esq.

    Linklaters LLP

September 16, 2025
Jorge F. Scarinci
Chief Financial Officer
Macro Bank Inc.
Avenida Eduardo Madero 1172, 24th Floor
C1106ACY City of Buenos Aires
Argentina
Re:Macro Bank Inc.
Form 20-F for Fiscal Year Ended December 31, 2024
File No. 001-32827
Dear Jorge F. Scarinci:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for Fiscal Year Ended December 31, 2024
Analysis of the allowance for loan losses and other financing, page 134
1.Please tell us and revise future filings to clarify what “variations” represent in your
ECL rollforwards.
Credit loss expense on financial assets, page 162
2.Please provide us and revise future filings to disclose a breakdown of the credit loss
expense on financial assets recognized in each period presented in your filing by
nature of financial asset. Also, provide us a reconciliation of the credit loss expense
recognized for loans and other financing to the ECL rollforward disclosed on page
134 for 2024 and 2023 and revise future filings as necessary to ensure investors
understand the relationship between the credit loss recognized and the line-items
included in the ECL rollforward.

September 16, 2025
Page 2
29. Income Tax, page F-71
3.Please revise future filings to separately quantify the impact of each material
item resulting in a material difference between your effective tax rate and the amounts
obtained by applying the current tax rate in Argentina to the income carrying
amount.
            In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
            Please contact Victor Cecco at 202-551-2064 or Michael Volley at 202-551-3437
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Paola Gayoso

July 15, 2013

Via E -mail
Mr. Jorge Pablo Brito
Chief Financial Officer
Banco Macro S.A.
Sarmiento 447
City of Buenos Aires, Argentina

Re: Banco Macro S.A.
Form 20-F for the Fiscal Year Ended December 31, 2012
Filed April 26, 2013
File No. 001-32827

Dear Mr. Brito :

We have completed our review of your filing .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy  of the disclosure in the filing  to be certain that the filing include s the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Michael R. Clampitt

Michael R. Clampitt
Senior Attorne y

CORRESP
1
filename1.htm

        VIA EDGAR

        July 5, 2013

        .

Michael Clampitt

Senior Attorney

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re. Banco Macro S.A.

  Form 20-F for Fiscal Year Ended December 31, 2012

  Filed April 26, 2013

  File No. 001-32827

Dear Mr. Clampitt:

By letter dated June 10, 2013, the staff
of the Securities and Exchange Commission (the “Staff”) provided certain comments related to the annual report
on Form 20-F for the fiscal year ended December 31, 2012 (the “2012 Form 20-F”) filed by Banco Macro S.A. (Macro
Bank, Inc.) (the “Company”) with the Securities and Exchange Commission (the “Commission”)
on April 26, 2013. In response to the Staff’s comments, the Company submits the responses below.

For your convenience, the Company
has reproduced below in italics the Staff’s comments and has provided responses immediately below the comments.

Comment No. 1

General

  1. We note that you filed an 8-A12B for the Class B ordinary shares on March 3, 2006. Therefore,
it appears that you should be listing such shares on the Form 20-F as “Securities registered or to be registered pursuant
to Section 12(b) of the Act.” Please explain why you have not done so. In addition, please tell us how you concluded that
there is a reporting obligation pursuant to Section 15(d) of the Act for the 9.75% junior subordinated bonds.

Response to Comment No. 1

The Company respectfully notes that it has listed
its Class B ordinary shares as “Securities registered or to be registered pursuant to Section 12(b) of the Act” on
the cover of the 2012 Form 20-F.

The Company’s 9.75% junior subordinated bonds
(the “9.75% Bonds”) were offered pursuant to a registration statement on Form F-4 under the Securities Act of
1933, as amended (the “Securities Act”), that became effective on August 16, 2007.  Although the Company’s
reporting obligation pursuant to Section 15(d) of the Act in connection with its 9.75% Bonds is suspended because other securities
of the Company registered pursuant to Section 12(b) of the Act are outstanding, the Company has included specific disclosure referring
to the 9.75% Bonds in its annual reports on Form 20-F, under “Item 3—Risk Factors” and “Item 9—The
Offer and Listing,” among others.  For these reasons, the Company has elected to list the 9.75% Bonds as “Securities
for which there is a reporting obligation pursuant to Section 15(d) of the Act,” notwithstanding the fact that such obligation
is currently suspended.

Comment No. 2

Item 4. Information on the Bank

B. Business Overview

Banking Regulation and Supervision

Limits for affiliated individuals, page 42

2. We note your disclosure on page 43 that
the Central Bank has placed certain restrictions on financial institutions whose notes are rated below “BB” by a local
rating agency. Please tell us whether your notes are currently rated above or below this threshold, and explain whether the restrictions
apply to you. If they do, please revise future filings to note this fact, and include a discussion of how such restrictions impact
your financial assistance granted to related parties. If applicable, please include a draft of your revised disclosures to be made
in future filings in response to this comment.

Response to Comment No. 2

We respectfully note that the restrictions referred to in the
Staff’s comment apply when financial institutions seek to refinance, extend or renew financial assistance granted to “related
parties,” as such term is defined on page 93 of the 2012 Form 20-F, and such related parties have a credit rating that is
not “normal” or their notes are rated below "BB" by a local rating agency. These restrictions are determined
by reference to the ratings of the related parties rather than the ratings of the financial institutions and, therefore, the "BB"
threshold does not apply to the Company.

As requested, please note that the 9.75% Bonds are currently rated "A(Arg)+" by Fitch Argentina Calificadora de Riesgo
S.A. and "(CCC+)= Caa1.ar” by Moody’s Latin America Calificadora de Riesgo S.A. and the Company’s 8.50%
Notes due 2017 are currently rated “AA (Arg)” by Fitch Argentina Calificadora de Riesgo S.A. and “(A)=A2.ar”
by Moody’s Latin America Calificadora de Riesgo S.A.

Comment No. 3

Financial Statements

Note 33.2. Exposure
to Argentine Public Sector and Private Securities

(a) Loans – Non-financial
federal government sector, pages F-65-F-66

3. Please tell us and expand the note in
future filings to provide all the disclosures required by ASC 310-30-50 with regard to loans and debts acquired with deteriorated
credit quality.

Response to Comment No. 3

The Company has reviewed the disclosure requirements of ASC
310-30-50 on loans and debts acquired with deteriorated credit quality.

Taking into account the terms of loans to the non-financial
federal government sector acquired with deteriorated credit quality and considering that, historically, the government has not
prepaid them, the Company does not expect prepayments to occur and, therefore, has concluded that under ASC 310-30-50-1 such prepayments
need not be considered in the determination of contractual cash flows and cash flows expected to be collected.

The following table (prepared in accordance with ASC 310-30-50-2
(a.1)) presents the outstanding balance of loans to the non-financial federal government sector acquired with deteriorated credit
quality and related carrying amount at the beginning and end of each year:

    Outstanding balance (*)
    Carrying amount

    Year ended
December 31,
    Year ended

December 31,

    2012
    2011
    2012
    2011

     (in thousands of pesos)

    Beginning of the year
      308,966
      280,629
      112,602
      104,656

    End of year
      325,548
      308,966
      119,883
      112,602

(*) includes the undiscounted sum of all amounts, including
principal, interest, fees and CER adjustments (benchmark stabilization coefficient) under the loans owed at the reporting date.

The following table reconciles the amounts of accretable yield
of loans to the non-financial federal government sector acquired with deteriorated credit quality at the beginning and end of each
year, as required by ASC 310-30-50-2 (a.2):

    Year ended
December 31,

    2012
    2011
    2010

    (in thousands of pesos)

    Accretable yield at the beginning
      26,629
      35,757
      22,330

    Accretion
      (23,677 )
      (25,502 )
      (19,420 )

    Disposals
      (2,010 )
      -
      (385 )

    Reclassification from nonaccretable yield
      37,564
      16,374
      33,232

    Accretable yield at the end
      38,506
      26,629
      35,757

With respect to ASC 310-30-50-2 (a.3), the Company has not acquired
loans or debt securities with deteriorated credit quality during 2012, 2011 and 2010.

The Company notes that it applies the income recognition model
required by ASC 310-30. Therefore, the disclosures required by ASC 310-30-50-2 (a.4) do not apply to the Company.

In addition, the following table presents the activity in the
allowances required by ASC 310-30-50-2 (b) in connection with loans to the non-financial federal government sector acquired with
deteriorated credit quality:

    Allowances for Loans acquired with Deteriorated Credit Quality

    Year ended
December 31,

    2012
    2011
     2010

    (in thousands of pesos)

    Beginning balance
      -
      20
      147

    Provision for loan losses
      4,294
      -
      20

    Recoveries
      -
      (20 )
      (147 )

    Ending balance
      4,294
      -
      20

The Company takes note of the Staff´s comment and will
expand the relevant note in future filings to include the applicable disclosures described in the previous paragraphs.

Comment No. 4

Financial Statements

Note 33.2. Exposure
to Argentine Public Sector and Private Securities

(b) Government Securities, (c) Instruments
issued by Central Bank of Argentina and (d) Securities in financial trust, pages F-66-F-69

4. Please tell
us and expand the note in future filings to provide the disclosures required by ASC 320-10-50-6-8 with regard to investments in
an unrealized loss position at 12/31/12 and 12/31/11. In addition, state the basis on which the cost of a security sold was determined
pursuant to ASC 320-10-50-9 (b).

Response to Comment No. 4

The Company has reviewed the disclosure requirements of ASC
320-10-50-6-8.

The following table (prepared in accordance with ASC 320-10-50-6
(a.1) and (a.2) and ASC 320-10-50-7), presents the gross unrealized losses and fair value of securities classified as available
for sale by length of time for each category of securities that have been in a continuous loss position:

    Less than 12 months
    12 months or more
    Total

    Gross Unrealized losses
    Fair Value
    Gross Unrealized losses
    Fair

Value
    Gross Unrealized losses
    Fair

Value

    (in thousands of pesos)

    December 31, 2012

    Government securities
      (21 )
      42,760
      (173 )
      47,233
      (194 )
      89,993

    Instruments issued by Central Bank of Argentina
      (31 )
      50,781
      -
      -
      (31 )
      50,781

    Securities in financial trust and other
      (3,856 )
      130,260
      (3,734 )
      60,789
      (7,590 )
      191,049

    Total
      (3,908 )
      223,801
      (3,907 )
      108,022
      (7,815 )
      331,823

    December 31, 2011

    Government securities
      (2,042 )
      46,247
      -
      -
      (2,042 )
      46,247

    Instruments issued by Central Bank of Argentina
      (41 )
      4,078
      -
      -
      (41 )
      4,078

    Securities in financial trust and other
      (12,474 )
      276,485
      (2,603 )
      46,101
      (15,077 )
      322,586

    Total
      (14,557 )
      326,810
      (2,603 )
      46,101
      (17,160 )
      372,911

For purposes of determining whether the decline in fair value
for these categories of securities qualifies as “other than temporary impairment,” the Company has considered the following
factors:

 · The decline in fair value is not attributable to credit quality. It solely derives from adverse interest rate fluctuations
of observable inputs of similar instruments according to their fair value hierarchy.

 · Future principal payments will be sufficient to recover the current amortized cost of these investments.

 · The Company has the intention to hold these securities at least until their fair value recovers to a level that exceeds their
amortized cost.

 · The extent to which the fair value has been less than the amortized cost is not relevant for these
categories of securities.

The Company has concluded that the decline in fair value for
these securities does not qualify as “other than temporary impairment.” Consequently, the disclosure requirements of
ASC 320-10-50-8 do not apply.

Pursuant to ASC 320-10-50-9 (b), the Company notes that the
specific identification method was used in order to determine the cost of securities sold.

The Company takes note of the Staff´s comment and will
expand the relevant note in future filings to include the applicable
disclosures described in the previous paragraphs.

Comment No. 5

Financial Statements

Note 33.4 Allowance for Loan Losses, pages F-69-F-78

5. Please tell
us and expand the note in future filings to provide the following information:

 · The basis of accounting for loans pursuant to ASC 310-10-50-2 (a)

 · The accounting policies for off balance sheet credit exposures pursuant to ASC 310-10-50-9
&10

 · The amount of foreclosed and repossessed assets pursuant to ASC 310-10-50-11

 · A discussion of the risk characteristics relevant to each portfolio segment pursuant to ASC 310-10-50-11B (a) (2)

 · A description of the policy for charging off uncollectible financing receivables pursuant to ASC 310-20-50-11B (b)

 · By portfolio segment, qualitative information about how modifications/defaults are factored into the determination of the
allowance for credit losses pursuant to ASC 310-10-50-33 and 34 (b)

Response to Comment No. 5

In response to your comments regarding disclosures relating
to allowances for loan losses, the Company has reviewed the relevant ASC requirements.

 · The basis of accounting for loans pursuant to ASC 310-10-50-2 (a)

According to ASC-310-10-50-2 (a), loans are measured
at their amortized cost using the effective interest rate, after deduction of any allowance for loan losses.

 · The accounting policies for off balance sheet credit exposures pursuant to ASC 310-10-50-9 & 10

In the normal course of business, the Company enters
into transactions involving off balance sheet financial instruments to handle risk management and meet trading and financing needs
of its customers and for the Company’s proprietary trading and assets and liabilities management purposes.

In determining whether to enter
into transactions involving off balance sheet financial instruments, the Company follows the credit policies it uses to grant loans.

The management of the Company believes
that the outstanding off balance sheet items do not represent an unusual credit risk.

The Company’s exposure to credit loss in the event
of the counterparties’ failure to fulfill their commitments to extend credit or their obligations under guarantees granted
and foreign trade acceptances is represented by the contractual notional amount of these instruments. For further information see
Note 33.12 to the Company’s audited consolidated financial statements as of and for the three years ended December 31, 2012.

The process to determine allowances for off balance
sheet credit exposures is similar to the methodology used for loans (see Note 33.4 to the Company’s audited consolidated
financial statements as of and for the three years ended December 31, 2012). The provision charged to expense is determined by
management based upon client classification, actual loss experience, current and expected economic conditions, delinquency aging
and evaluation of probable losses in the current credit portfolio. Any probable loss amounts are recognized as allowances in the
consolidated balance sheet.

 · The amount of foreclosed and repossessed assets pursuant to ASC 310-10-50-11

The Company had foreclosed assets, for an amount of
6,064 and 10,489 (in thousands of pesos) as of December 31, 2012 and 2011, respectively, as described in Note 24.2 to the Company´s
audited consolidated financial statements as of and for the three years ended December 31, 2012.

The Company did not hold any repossessed assets as of
December 31, 2012 and 2011.

 · A discussion of the risk characteristics relevant to each portfolio segment pursuant to ASC 310-10-50-11B (a) (2)

The Company’s retail portfolio consists principally
of personal loans and credit card loans. Personal loans include mainly financing granted to clients under the “Plan Sueldo”
payroll services. Clients enrolled in this type of services receive their wages directly through their accounts at the Company.
Payments on such loans are debited directly from the clients’ wages on the due date. The most significant factors affecting
the Company’s retail portfolio’s credit risk are employment rates and real wages.

The Company’s commercial portfolio is currently
diversified among clients of different size (small, medium-sized businesses and corporations) and who are active in different economic
sectors (mainly the agricultural, food, services and construction sectors - see Note 22 to the Company’s audited consolidated
financial statements as of and for the three years ended December 31, 2012). The risks associated with this portfolio are principally
related to the specific economic performance of each individual client and to economic factors, such as the price and demand of
products and services and competitiveness, among others.

The Company implements monitoring, control and risk-m

CORRESP
1
filename1.htm

        Writer’s Direct Dial: (212) 225-2708

        E-Mail: adelacruz@cgsh.com

        VIA EDGAR

        June 17, 2013

        .

Michael Clampitt

Senior Attorney

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re. Banco Macro S.A.

  Form 20-F for Fiscal Year Ended December 31, 2012

  Filed April 26, 2013

  File No. 001-32827

Dear Mr. Clampitt:

By letter dated June 10, 2013, the staff
of the Securities and Exchange Commission (the “Staff”) provided certain comments related to the annual report
on Form 20-F for the fiscal year ended December 31, 2012 filed by our client, Banco Macro S.A. (Macro Bank, Inc.) (the “Company”),
with the Securities and Exchange Commission on April 26, 2013. The Staff’s letter requested the Company’s response
within ten business days of the letter’s date.

While the Company has made progress in
preparing its response, given the local holidays and based on a review of its internal resources, the Company concluded that it
will require additional time to consider the Staff’s comments and prepare its response. Therefore I respectfully advise that
the Company expects to submit its response to the Staff’s comments by July 8, 2013.

We are grateful for the Staff’s
accommodation in this matter. If you have any questions or wish to discuss any matters relating to the
foregoing, please do not hesitate to contact me at (212) 225-2208.

    Sincerely,

    /s/ Andrés de la Cruz

    Andrés de la Cruz

    c.c.
    Chris Harley –Securities and Exchange Commission

        David Irving –Securities and Exchange Commission

        Erin Purnell –Securities and Exchange Commission

    Jorge Pablo Brito – Banco Macro S.A.

    Jorge Scarinci – Banco Macro S.A.

June 10, 2013

Via E -mail
Mr. Jorge Pablo Brito
Chief Financial Officer
Banco Macro S.A.
Sarmiento 447
City of Buenos Aires, Argentina

Re: Banco Macro S.A.
 Form 20-F for the Fiscal Year Ended December 31, 2012
Filed April 26, 2013
File No. 001 -32827

Dear Mr. Brito :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand  your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your fac ts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

General
1. We note that you filed an 8 -A12B for the Class B ordinary shares on March 3, 2006.
Therefore, it appears that you should be listing such shares on the Form 20 -F as
“Securities registered or to be registered pursuant to Section 12(b) of  the Act.”
Please explain why you have not done so.  In addition, please tell us how you
concluded that there is a reporting obligation pursuant to Section 15(d) of the Act for
the 9.75% junior subordinated bonds.
Item 4. Information on the Bank
B. Busine ss Overview
Banking Regulation and Supervision
Limits for affiliated individuals, page 42

Mr. Jorge Pablo Brito
Banco Macro S.A.
June 10, 2013
Page 2

2. We note your disclosure on page 43 that the Central Bank has placed certain
restrictions on financial institutions whose notes are rated below “BB” by a local
rating  agency.  Please tell us whether your notes are currently rated above or below
this threshold, and explain whether the restrictions apply to you.  If they do, please
revise future filings to note this fact, and include a discussion of how such
restrictions  impact your financial assistance granted to related parties.  If applicable,
please include a draft of your revised disclosures to be made in future filings in
response to this comment.

Financial Statements

Note 33.2. Exposure to Argentine Public Sector  and Private Securities

(a) Loans – Non-financial federal government sector, pages F -65-F-66

3. Please tell us and expand the note in future filings to provide all the disclosures
required by ASC 310 -30-50 with regard to loans and debts acquired with
deteriorat ed credit quality.

(b) Government Securities, (c) Instruments issued by Central Bank of Argentina and (d)
Securities in financial trust, pages F -66-F-69

4. Please tell us and expand the note in future filings to provide the disclosures required
by ASC 320-10-50-6-8 with regard to investments in an unrealized loss position at
12/31/12 and 12/31/11 . In addition, state the basis on which the cost of a security
sold was determined pursuant to ASC 320 -10-50-9 (b).

Note 33.4 Allowance for Loan Losses, pages F-69-F-78

5. Please tell us and expand the note in future filings to provide the following
information:

 The basis of accounting for loans pursuant to ASC 310 -10-50-2 (a)

 The accounting policies for off balance sheet credit exposures pursuant to
ASC 310 -10-50-9 &10

 The amount of foreclosed and repossessed assets pursuant to ASC 310 -10-
50-11

Mr. Jorge Pablo Brito
Banco Macro S.A.
June 10, 2013
Page 3

 A discussion of the risk characteristics relevant to each portfolio segment
pursuant to ASC 310 -10-50-11B (a) (2)

 A description of the policy for charging off uncoll ectible financing
receivables pursuant to ASC 310 -20-50-11B (b)

 By portfolio segment, qualitative information about how
modifications/defaults are factored into the determination of the allowance
for credit losses pursuant to ASC 310 -10-50-33 and 34 (b)

Note 33.4 c. 1  Troubled Debt Restructuring , pages F -74-F-75

6. Please tell us and expand the detail o f restructured loans to clearly identify in future
filings both accruing and non -accruing troubled -debt restructured loans by loan
category.  In addition, te ll us and clearly identify troubled -debt restructured loans in
Note 33.4 d.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the  federal securities laws of the United States.

You may contact Chris Harley at (202) 551 -3695  or David Irving  at (202) 551 -3321 if
you have questions regarding comments on the financial statements and related matte rs.  Please
contact Erin Purnell  at (202)  551-3454  or me at (202) 551 -3434  with any other questions.

Sincerely,
 /s/ Michael R. Clampitt

 Michael Clampitt
Senior Attorney

UNITED STATES
SECURITIES  AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE

November 5, 2010

Via U.S. Mail and Facsimile

Jorge Scarinci Financial and Investor Relations Manager Macro Bank, Inc. 401 Sarmiento, 4th Floor Buenos Aires—C1041AAI, Argentina
Re: Macro Bank, Inc.
 Form 20-F for Fiscal Year Ended December 31, 2009
Filed June 1, 2010 File No. 001-32827

Dear Mr. Scarinci:
 We have completed our review of your fili ngs and do not have any further comments at
this time.
Sincerely,

Michael Seaman Special Counsel

CORRESP
1
filename1.htm

                    VIA EDGAR AND FACSIMILE

                    Sarmiento
      447 – C1041AAI

                    C.A.B.A
      – Rep. Argentina

                    .

                  Mr.
      Michael Seaman

                  September
      27, 2010

                  Special
      Counsel

                  Mr.
      Matt McNair

                  Attorney-Adviser

                  Division
      of Corporation Finance

                  Securities
      and Exchange Commission

                  100
      F Street, NE, Washington, D.C. 20549

                  Fax:
      (703) 813-6983

              Re.

              Macro
      Bank, Inc.

    Form
20-F for Fiscal Year Ended December 31, 2009

    Filed June 1, 2010

    File No. 001-32827

    Dear Mr.
Seaman:

    By letter
dated September 13, 2010, the staff of the Securities and Exchange Commission
(the “Staff”)
provided certain comments on Banco Macro S.A. (Macro Bank, Inc.) (the
“Company”)’s
annual report on Form 20-F for the fiscal year ended December 31, 2009 (the
“2009 Form
20-F”), which was filed with the Securities and Exchange Commission (the
“Commission”)
on June 1, 2010.  In response to the Staff’s comments, the Company
submits the responses below.

    For your
convenience, the Company has reproduced below in italics the Staff’s comments
and has provided responses immediately below the comments.

    Comment No.
1

    Item 4. Information on the
Bank

    Allocation of the Allowance
for Loan Losses, page 53

              1.
      Please revise future filings to present this information for five years as
      required by Industry Guide 3.

    Response to Comment No.
1

    The
Company will revise future filings to present the information requested for five
years.

    Comment No.
2

    Item 7. Major Shareholders
and Related Party Transactions

    B. Related Party
Transactions, page 87

    2.
Please provide to the staff the information required by Item 7.B.2 of Form 20-F
and revise future filings accordingly. Alternatively, confirm, if accurate, that
Instruction 2 to Item 7.B is applicable and revise future filings
accordingly.

        1

    Response to Comment No.
2

    Instruction
2 to Item 7.B is applicable to the Company, and the Company will conform its
disclosure to such instruction in future filings.

    Comment No.
3

    Item 10. Additional
Information

    C. Material Contracts, page
94

    3. Please provide us with a detailed
explanation of the analysis you undertook to conclude that you have no material
contracts.

    Response to Comment No.
3

    In
connection with the preparation of the 2009 Form 20-F, the Company conducted
internal inquiries to obtain the information necessary to update its disclosure
in accordance with the instructions to Form 20-F.  These inquiries
included, the identification of contracts to which the Company or any subsidiary
is a party that (i) are not contracts that ordinarily accompany the kind of
business that the Company and its subsidiaries conduct, (ii) fall under any of
the categories set forth in paragraph 4(b) of the “Instructions as to Exhibits”
of Form 20-F, or (iii) are otherwise considered material under paragraph 4(c) of
the “Instructions as to Exhibits” of Form 20-F.

    Based on
such inquiries, the Company concluded that, during the two years immediately
preceding publication of the 2009 Form 20-F, the Company and its subsidiaries
did not enter into or become a party to any contract that is required to be
disclosed under Item 10.C of Form 20-F.

    Comment No.
4

    Item 18. Financial
Statements

    31. Consolidated Income
Statements and Balance Sheet, page F-62

    4.
The Consolidated Income Statement on page 53 indicates it is presented under the
measurement methods provided by the Central Bank but under the US SEC disclosure
requirements.  Please tell us and revise future filings to clarify the
specific nature of the organization and development expenses you are amortizing
and the provision for losses other receivables and other allowance that you
present in the Consolidated Income Statement.  Clarify the US GAAP
guidance that you relied on for your reconciliation to US GAAP and the
associated US GAAP accounting policies.

    Response to Comment No.
4

    As
indicated in the Company’s audited consolidated financial statements as of and
for the years ended December 31, 2009 and 2008 (see notes 4.4.l), 26 and 35.5.),
“Amortization of organization and development expenses” includes
primarily:

        2

              ·

              Costs
      related to information technology projects (purchased software): under
      Central Bank Rules, the Company records as expenses software costs
      relating to preliminary application development and post–implementation
      stages of software development.  Central Bank Rules allow
      capitalization of certain costs that are not eligible for capitalization
      under ASC 350- 40.  The Company follows the requirements of ASC
      350- 40 for its US GAAP policy with respect to such costs. Please see also
      note 35.5.b) of the Company’s audited consolidated financial statements as
      of and for the years ended December 31, 2009 and
  2008.

              ·

              Differences
      due to court orders: under Central Bank Rules, the Company records under
      this item exchange differences related to payments and provisions made by
      the Company in relation to the constitutional protection and court
      judgments resulting from court decisions mentioned in note 2 to the
      Company’s audited consolidated financial statements as of and for the
      years ended December 31, 2009 and 2008.  Under ASC 450, the
      right to obtain compensations for this asset is deemed a contingent gain
      that cannot be recognized until realized and, therefore, the Company
      includes this in the US GAAP reconciliation. Please see also note 35.5.a)
      of the Company’s audited consolidated financial statements as of and for
      the years ended December 31, 2009 and
2008.

              ·

              Organization
      costs: under Central Bank Rules, the Company records under this item cost
      inherent to the set up and organization of the Bank. Under ASC 720-15,
      these organization costs are expensed. Please see also note 35.5.c) of the
      Company’s audited consolidated financial statements as of and for the
      years ended December 31, 2009 and
2008.

    Additionally,
as described in the Company’s audited consolidated financial statements as of
and for the years ended December 31, 2009 and 2008 (see notes 4.4.o) and 27),
“Provision for losses on other receivables and other allowances” mainly includes
expenses related to contingent liabilities for probable claims, lawsuits and
other proceedings, including those related to labor and other obligations. The
amounts have been accrued in accordance with Central Bank Rules, which are
similar to ASC 450 “Contingencies”.

    The
Company takes note of the Staff´s comment and will review future filings to
include cross references in note 31 to the notes mentioned in previous
paragraphs and vice-versa.

    Comment No.
5

    35. Summary of Significant
Differences … page F-68

    5.
Please tell us and revise future filings to provide a discussion of your
accounting policy for repurchase agreements and how it complies with US GAAP.
Discuss whether you record these transactions as sale or as secured financings
and, in each case, how you determined the appropriateness of your
accounting.

        3

    Response to Comment No.
5

    With
regard to the Company’s repurchase agreements, the Company determined that
Central Bank Rules are similar to ASC 860. As a consequence, the Company
recorded all of those agreements as secured financings and there is no
difference under US GAAP. There are no agreements that would qualify for sales
under applicable accounting policies.

    The
Company takes note of the Staff´s comment and will review future filings to
clarify our accounting policy for repurchase agreements under US
GAAP.

    Comment No.
6

    35.1. Income Taxes, page
F-68

    6.
Please tell us and revise future filings to disclose why it is more likely than
not that you will not realize a portion of your deferred tax assets such that a
valuation allowance is required.  Clearly disclose how you determined
the amount of the valuation allowance that was required at each balance sheet
date.

    Response to Comment No.
6

    In
accordance with ASC 740-10-30-16 through 30-25, the Company evaluates for each
consolidated entity all available evidence, both positive and negative and the
future realization of the tax benefit over a relatively short period of time
(considering future reversals of existing taxable temporary differences, future
taxable income exclusive of reversing temporary differences and carryforwards
and tax-planning strategies). The Company considers using future projections of
income for only relatively short periods of time to be a reasonable approach,
given Argentina's history of economic volatility.

    In
determining the amount of the valuation allowance for deferred tax assets
required at each balance sheet date, the Company applies ASC 740 as mentioned in
note 35.1. to the Company’s audited consolidated financial statements as of and
for the years ended December 31, 2009 and 2008. At each balance sheet date and
since the Initial Public Offering, the Company has applied the same
policy.

    The
Company takes note of the Staff´s comment and will review future filings to
clarify the disclosures for valuation allowances for deferred tax.

    Comment No.
7

    35.2 Exposure to Argentine
Public Sector and Private Securities, page F-70

    7.
Please provide us with a schedule that presents securities available for sale in
a tabular format that reconciles them to the balance sheet in footnote 31 and
that includes the disclosure requirements of ASC
320-10-50-2.  Similarly, please address the disclosure requirements of
ASC 320-10-50 sub paragraphs 6 and 7.  Revise future filings to
include this information.

        4

    Response to Comment No.
7

    The
following tabular format reconciles securities classified as available for sale
(note 35.2. to the Company’s audited consolidated financial statements as of and
for the years ended December 31, 2009 and 2008) to the balance sheet under
Central Bank Rules (note 31) and includes the disclosure requirements of ASC
320-10-50-2:

                      As of December 31, 2009

                      Securities

                      Balance Sheet

                      Amortized Cost

                      Net Unrealized

                      Gains

                      Fair Value

                      Holdings
      in special investment accounts

                    659,371

                    578,755

                    318,487

                    897,242

                      Instrument
      issued by Central Bank of Argentina and other unlisted
      securities

                    (1)
      5,374,035

                    5,359,701

                    (4,622
                    )

                    5,355,079

                    6,033,406

                    5,938,456

                    313,865

                    6,252,321

                      As of December 31, 2008

                      Securities

                      Balance Sheet

                      Amortized Cost

                      Net Unrealized

                      Gains

                      Fair Value

                      Holdings
      in special investment accounts

                    448,305

                    459,797

                    (51,130
                    )

                    408,667

                      Instrument
      issued by Central Bank of Argentina and other unlisted
      securities

                    (1)
      3,967,708

                    3,957,135

                    (53,662
                    )

                    3,903,473

                    4,416,013

                    4,416,932

                    (104,792
                    )

                    4,312,140

              (1)

              As of December 31, 2009
      and 2008, it includes 521,159 and 5,626, respectively, related to
      available for sale securities under repurchased agreements classified in
      note 31 as “Federal Funds sold and securities purchased under resale
      agreements of similar
arrangements”.

    In
addition, the following table presents the contractual maturities of the
securities available for sale as of December 31, 2009 (see notes 21. and 24. for
the contractual maturities under Central Bank Rules):

                        Maturing

                        Securities

                        Within 1

                        year

                        After 1 year

                        but within 5

                        years

                        After 5 year

                        but within

                        10 years

                        After 10

                        years

                        Without

                        due date

                        Total

                        Holdings
      in special investment accounts

                      19,308

                      633,028

                      219,818

                      25,088

                      0

                      897,242

                        Instrument
      issued by Central Bank of Argentina and other unlisted
      securities

                      5,228,164

                      107,193

                      19,722

                      0

                      0

                      5,355,079

                      5,247,472

                      740,221

                      239,540

                      25,088

                      0

                      6,252,321

    In
accordance with the disclosure requirements of ASC 320-10-50 sub paragraph 6 and
7, the following table presents information regarding investments with
unrealized loss position:

        5

                    For the years ended December 31

                    2009

                    2008

                    Securities

                    Gross Unrealized

                    losses

                    Fair Value

                    Gross Unrealized

                    losses

                    Fair Value

                    Holdings
      in special investment accounts

                  0

                  0

                  (51,766
                  )

                  355,130

                    Instrument
      issued by Central Bank of Argentina and other unlisted
      securities

                  (19,919
                  )

                  3,510,618

                  (61,517
                  )

                  2,450,063

                  (19,919
                  )

                  3,510,618

                  (113,283
                  )

                  2,805,193

    As of
December 31, 2009 and 2008, all investments had been in a continuous unrealized
loss position for less than 12 months.

    In
addition, as of December 31, 2009 the unrealized losses were not significant.
However, the Company evaluated the Argentine macroeconomic environment and the
decline in fair value to determine whether it was other than temporary and
concluded that there was no need to record anything other than temporary
impairment.

    The
Company takes note of the Staff´s comment and will review future filings to
include the disclosure requirements of ASC 320-10-50 paragraphs 2, 6 and
7.

    ******

    In
accordance with the requests at the end of your letter, the Company hereby
acknowledges that (i) it is responsible for the adequacy and accuracy of the
disclosure in it

UNITED STATES
SECURITIES  AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE

September 13, 2010

Via U.S. Mail and Facsimile

Jorge Scarinci Financial and Investor Relations Manager Macro Bank, Inc. 401 Sarmiento, 4th Floor Buenos Aires—C1041AAI, Argentina
Re: Macro Bank, Inc.
 Form 20-F for Fiscal Year Ended December 31, 2009
Filed June 1, 2010 File No. 001-32827

Dear Mr. Scarinci:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 20-F for Fiscal Year Ended December 31, 2009

 Item 4.  Information on the Bank

 Allocation of the Allowance for Loan Losses, page 53

1. Please revise future filings to present this information for five years as required by
Industry Guide 3.

Jorge Scarinci
Macro Bank, Inc. September 13, 2010 Page 2  Item 7.  Major Shareholders and Related Party Transactions

 B.  Related Party Tr ansactions, page 87

2. Please provide to the staff the informati on required by Item 7.B.2 of Form 20-F and
revise future filings ac cordingly.  Alternatively, confirm, if accurate, that Instruction 2 to
Item 7.B is applicable and revise future filings accordingly

Item 10.  Additional Information
 C.  Material Contracts, page 94

3. Please provide us with a detailed explanati on of the analysis you undertook to conclude
that you have no material contracts.
 Item 18.  Financial Statements

 31.  Consolidated Income Statements and Balance Sheet, page F-62

4. The Consolidated Income Statement on page  53 indicates it is presented under the
measurement methods provided by the Centra l Bank but under the US SEC disclosure
requirements.  Please tell us and revise future filings to clarify the specific nature of the
organization and development expenses you ar e amortizing and the provision for losses
other receivables and other allowance that you present in  the Consolidated Income
Statement.  Clarify the US GAAP guidance th at you relied on for your reconciliation to
US GAAP and the associated US GAAP accounting policies.
 35.  Summary of Significant Differences …, page F-68

 General

5. Please tell us and revise future filings to  provide a discussion of your accounting policy
for repurchase agreements and how it comp lies with US GAAP.  Discuss whether you
record these transactions as sale or as secured financings and, in each case, how you
determined the appropriateness of your accounting.
 35.1.  Income Taxes, page F-68

6. Please tell us and revise future filings to disc lose why it is more likely than not that you
will not realize a portion of your  deferred tax assets such that a valuation allowance is

Jorge Scarinci
Macro Bank, Inc. September 13, 2010 Page 3
required.  Clearly disclose how you determin ed the amount of the valuation allowance
that was required at each balance sheet date.
 35.2.  Exposure to Argentine Public Sect or and Private Secu rities, page F-70

7. Please provide us with a schedul e that presents securities avai lable for sale in a tabular
format that reconciles them to the balan ce sheet in footnote 31 and that includes the
disclosure requirements of ASC 320-10-50-2.  Similarly, please addr ess the disclosure
requirements of ASC 320-10-50 s ub paragraphs 6 and 7.  Revise  future filings to include
this information.  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Paul Cline,  Staff Accountant, at (202)  551-3851 or Kevin W. Vaughn,
Accounting Branch Chief, at (202) 551-3494 if you have questions regarding comments on the
financial statements and related matters.  Plea se contact Matt McNair, Attorney-Adviser, at
(202) 551-3583 or me at (202) 551- 3366 with any other questions.

Sincerely,

Michael Seaman Special Counsel

Mail Stop 4561     September 3, 2008
Via U.S. First Class Mail

Jorge Horacio Brito Chief Executive Officer Macro Bank Inc. Sarmiento 447 1041 Buenos Aires Republic of Argentina
Re: Macro Bank Inc.
Form 20-F Filed June 30, 2008 File No. 001-32827
 Dear Mr. Brito:
 We have completed our review of your Form 20-F and have no further comments
at this time.

Sincerely,

Gregory Dundas Senior Attorney
 cc: Hugo N.L. Bruzone, Esq.  Bruchou, Fernandez Madero & Lombardi  Ing. Butty 275, 12th Floor  C1001AFA – Buenos Aires, Argentina   By fax (646) 848-5009
Antonia E. Stolper, Esq.
 Shearman & Sterling LLP

CORRESP
1
filename1.htm

              Shearman &
      Sterling
      LLP

              FAX:
      646-848-5009

              www.shearman.com

              WRITER'S DIRECT
      NUMBER:

              (212)
      848-5009

                WRITER'S EMAIL
      ADDRESS:

                astolper@shearman.com

              August 28,
      2008

                  BY
      EDGAR AND FACSIMILE

              599
      LEXINGTON AVENUE

              NEW
      YORK, NY

              10022-6069

              ABU
      DHABI

              BEIJING

              BRUSSELS

              DÜSSELDORF

              FRANKFURT

              HONG
      KONG

              LONDON

              MANNHEIM

              MENLO
      PARK

              MUNICH

              NEW
      YORK

              PARIS

              ROME

              SAN
      FRANCISCO

              SÃO
      PAULO

              SHANGHAI

              SINGAPORE

              TOKYO

              TORONTO

              WASHINGTON,
      D.C.

      Mr. Matt
McNair

      Staff
Attorney

      Division
of Corporation Finance

      Securities
and Exchange Commission

      450 Fifth
Street, N.W.

      Washington,
D.C.  20549-0405

      Fax:
(202) 772-9208

      Banco Macro
S.A.,

      Form 20-F for Fiscal Year
Ended December 31, 2007

      Filed June 30,
2008

      File No.
001-32827

      Dear Mr.
McNair:

      Banco
Macro S.A., (the “Company”) has
received the Staff’s comment letter dated August 8, 2008 concerning the
above-referenced filing on Form 20-F.  On behalf of the Company, we
advise you as follows regarding your comments as noted below:

      SEC Comment No.
1.

      Item 3. Key
Information

      Selected
Financial Data, page 1

                1.

                Item
      3.A.3 on Form 20-F requires disclosure of the exchange rate in this
      section.  Please confirm that in future filings you will include
      a cross-reference to the section where exchange ratio information is
      located if it is disclosed other than in Item
3.

          Shearman
& Sterling LLP is a limited liability partnership organized in the United
States under
the laws of the State of Delaware, which laws limit the personal
liability of partners.

      Response
to Comment No. 1.

      In future
filings, the Company will include a cross-reference to the section where the
exchange ratio information is located if it is disclosed other than in Item
3.

      SEC Comment No.
2.

      Item 4.
Information on the Company

      C.
Organizational Structure

      Subsidiaries,
page 38

                2.

                Your
      disclosure does not fully comply with Item 4.C of Form
      20-F.  For example, it does not disclose the country of
      incorporation or residence of each subsidiary, nor does it disclose the
      proportion of ownership interest.  Please revise your future
      filings accordingly.

      Response
to Comment No. 2.

      The Company will fully comply with Item
4.C of Form 20-F in future filings.  This includes, but is not limited
to, disclosing the country of incorporation or residence of each subsidiary and
the proportion of ownership interest of each subsidiary.

      SEC Comment
No. 3.

      Item 7.
Major Shareholders and Related Party Transactions

      A. Major
Shareholders, page 82

                3.

                Please
      confirm that in future filings you will indicate whether the company’s
      major shareholders have different voting rights.  If major
      shareholders do not have different voting rights, please include an
      appropriate negative statement to that effect.  Refer to Item
      7.A.1(c) of Form 20-F

        Response to Comment No.
3.

      In future filings, the Company will
indicate whether the Company’s major shareholders have different voting
rights.  If the Company’s major shareholders do not have different
voting rights, the Company will include an appropriate negative statement to
that effect.

      SEC Comment
No. 4.

      Item 9. The
Offer and Listing

      A. Offer and
listing details, page 85

                  4.

                  This
      section does not fully comply with Item 9.A.4 of the Form
      20-F.  You must provide the annual high and low market prices
      for the five most recent full financial years.  Additionally,
      the host country market price must be provided for each covered period.
      Please revise your future filings to comply with this item
      requirement.

      Response to Comment No.
4.

      In future
filings, the Company will provide the annual high and low market prices for the
five most recent full financial years.  In addition, the Company will
provide the host country market price for each covered period in future
filings.

      SEC Comment No.
5.

      Item 10. Additional
Information

      Documents on Display, page
96

                5.

                The correct address for the
      public reference room of the Securities and Exchange Commission is 100 F
      Street, NE, Washington, D.C. 20549.  Please review your future
      filings accordingly.

      Response
to Comment No. 5.

      In future
filings, the Company will make certain that any references to the address of the
public reference room of the Securities and Exchange Commission reflect the
above address.

      SEC Comment No.
6.

      Exhibits

      Exhibits 12.1 and
12.2

              6.

                 The
      certifications omit a portion of the introductory language to paragraph
      4.  Please revise.  You may file an abbreviated
      amendment consisting of a cover page, explanatory note, signature page and
      paragraphs 1, 2, 4, and 5 of the certifications. Additionally, we remind
      you that certifications required under Exchange Act Rules 13a-14(a) and
      15d-14(a) must be in the exact form set forth in Form
      20-F.  Refer to Instructions as to Exhibits of the
      Form 20-F.

      Response
to Comment No. 6.

      The
Company has revised the certifications to include the language that was
inadvertently omitted from paragraph 4 of the certification.  Please
refer to the amendment, which includes a cover page, explanatory note, signature
page, and the amended certification.

      ******

      In accordance with the requests at the
end of your letter, the Company hereby acknowledges that it is responsible for
the adequacy and accuracy of the disclosure in its filing; staff comments or
changes to disclosure in response to staff comments do not foreclose the
Commission from taking any action with respect to the filing; and the Company
may not assert staff comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United
States.

      If you have any questions or wish to
discuss any matters relating to the foregoing, please contact me at 212-848-5009
or Mr. Jorge Horacio Brito of the Company at (011-54-11)
5222-8206.

      Very
truly yours,

      /s/
Antonia E. Stolper

                  cc:

                  Gregory Dundas – Senior Attorney –
      Securities and Exchange Commission

                  Paola Gayoso – Banco Macro
      S.A.

Mail Stop 4561     August 8, 2008    Jorge Horacio Brito Chief Executive Officer Macro Bank Inc. Sarmiento 447 1041 Buenos Aires Republic of Argentina
Re: Macro Bank Inc.
Form 20-F
Filed June 30, 2008 File No. 001-32827

Dear Mr. Brito:

We have reviewed your filing and have the following comments.  Where indicated, we
think you should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.   Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.   Form 20-F

 Item 3. Key Information

 Selected Financial Data, page 1

 1. Item 3.A.3 of Form 20-F requires disclosure of the exchange rate in this section.  Please confirm that in future filings you will include a cross-reference to the section where exchange ratio information is located if it is disclosed other than in Item 3.
Item 4. Information on the Company

Jorge Horacio Brito
Chief Executive Officer Macro Bank Inc.
Page 2   C. Organizational Structure

 Subsidiaries, page 38

 2. Your disclosure does not fully comply with Item 4.C of Form 20-F.  For example, it does not disclose the country of incorporation or residence of each subsidiary, nor does it disclose the proportion of ownership interest.  Please revise your future filings accordingly.
  Item 7. Major Shareholders and Related Party Transactions

 A. Major Shareholders, page 82

 3. Please confirm that in future filings you will indicate whether the company’s major shareholders have different voting rights.  If major shareholders do not have different voting rights, please include an appropriate negative statement to that effect.  Refer to Item 7.A.1(c) of Form 20-F.
 Item 9. The Offer and Listing

 A. Offer and listing details, page 85

 4. This section does not fully comply with Item 9.A.4 of the Form 20-F.  You must provide the annual high and low market prices for the five most recent full financial years.  Additionally, the host country market price must be provided for each covered period.  Please revise your future filings to comply with this item requirement.
 Item 10. Additional Information

 Documents on Display, page 96

 5. The correct address for the public reference room of the Securities and Exchange Commission is 100 F Street, NE, Washington, D.C. 20549.  Please revise your future filings accordingly.
 Exhibits

 Exhibits 12.1 and 12.2

 6. The certifications omit a portion of the introductory language to paragraph 4.  Please revise.  You may file an abbreviated amendment consisting of a cover page, explanatory note, signature page and paragraphs 1, 2, 4, and 5 of the certifications.  Additionally, we remind you that certifications required under Exchange Act Rules 13a-14(a) and 15d-

Jorge Horacio Brito
Chief Executive Officer Macro Bank Inc.
Page 3
14(a) must be in the exact form set forth in Form 20-F.  Refer to Instructions as to Exhibits of the Form 20-F.

  *  *  *  *  *

As appropriate, please amend your filing and respond to these comments within 10
business days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the amendment to expedite  our review.  Please furnish a cover letter with
your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.   We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.     In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:  ‚ the company is responsible for the adequacy and accuracy of the disclosure in the filing;
‚ staff comments or changes to disclosure in response to staff comments do not foreclose the
Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.     Please contact Matt McNair, Staff Attorn ey, at (202) 551-3583 or me at (202) 551-3436
with any questions.
Sincerely,

Gregory Dundas Senior Attorney

Jorge Horacio Brito
Chief Executive Officer Macro Bank Inc. Page 4  cc: Hugo N.L. Bruzone, Esq.  Bruchou, Fernandez Madero & Lombardi  Ing. Butty 275, 12
th Floor
 C1001AFA – Buenos Aires, Argentina   By fax (646) 848-5009
Antonia E. Stolper, Esq.
 Shearman & Sterling LLP